Roblox · Roblox Privacy and Cookie Policy · View original document ↗

Behavioral Advertising and Cross-Context Data Sharing

High severity High confidence Explicitdocumentlanguage Unique · 0 of 343 platforms
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Recent governance activity Roblox recorded 3 documented changes in the last 30 days.
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Document Record

What it is

Roblox uses your behavioral data and works with advertising partners who use cookies, pixels, and SDKs to serve you targeted ads based on your activity on Roblox and other websites. Users above the applicable age threshold are subject to this cross-context behavioral advertising.

This analysis describes what Roblox's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

Recent Activity

This document changed recently

Medium May 1, 2026

The updated policy restricts personalized advertising based on age. Users under 18 will see only nonpersonalized ads on the platform, while users 18 and older may see personalized ads if they provide consent where required. The revised language also removes the previous statement that the platform collects personal information from under-13 accounts for advertising purposes, clarifying that such data is not used for marketing. Users 18 or older can control whether they see personalized ads through Roblox account settings.

View change record →
Medium Apr 23, 2026

The updated policy adds explicit language disclosing that Roblox collects persistent identifiers (IP addresses and unique device identifiers) from all users, including children, for purposes including account authentication, ad frequency capping, network communications, and security. The policy states Roblox implements technical, contractual, and other measures to ensure these identifiers are not used for purposes outside the listed scope. This represents a clarification and formalization of practices rather than a change to what data is collected, but it does establish contractual limits on how that data may be used. You can review the full updated Privacy Policy to understand which persistent identifiers are collected and the specific operational purposes for which they are retained.

View change record →
Medium Mar 8, 2026

The updated policy clarifies that parent email addresses constitute the only personal information collected from child accounts under COPPA, rather than listing persistent identifiers. The policy now states that personalized ads are not enabled until age 18, rather than leaving this ambiguous when a child turns 13. These clarifications affect how parents and children understand what data Roblox collects and when advertising becomes personalized; however, the underlying data practices do not appear to have changed operationally. The policy removed detailed descriptions of collection purposes (such as internal operations), which means parents now have less granular explanation of data uses, though stated practices remain.

View change record →

Clause Stability Stable

0
Changes
3
Months Monitored
May 12, 2026
First Seen
May 20, 2026
Last Seen
This clause type exists across 3350 other provisions on other platforms.

Change history

removed Jun 24, 2026

Removal reflects shift away from broad third-party behavioral targeting disclosure, likely replaced by more restrictive age-tiered advertising policies that prohibit such practices for minors.

View full change record →
modified May 14, 2026

Previous version had only high-level mention of 'Third-Party Advertising Data Sharing' with no excerpt; current version adds detailed explanation of behavioral advertising mechanisms, partner tracking technologies, and cross-context data collection methods.

View full change record →

Consumer impact (what this means for users)

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.
  • Opt Out of Arbitration
    Navigate to your Roblox account Privacy Settings at https://www.roblox.com/my/account#!/privacy and use the 'Do Not Sell or Share My Personal Information' option to opt out of behavioral advertising data sharing.

How other platforms handle this

eBay Medium

We collect your personal data when you use our Services, create a new eBay account, provide us with information via a web form, add or update information in your eBay account, participate in online community discussions or otherwise interact with us.

Ledger Medium

At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.

Garmin Medium

If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...

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▸ View Original Clause Language DOCUMENT RECORD
"
We may use the personal information we collect to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We work with third-party advertising partners, including advertising networks, to display ads on our platform and other sites. These partners may use cookies, pixels, SDKs, and similar tracking technologies to collect information about your activities on our services and other websites to provide you targeted advertising based on your interests. We do not engage in cross-context behavioral advertising for users we know to be under the applicable age threshold.

— Excerpt from Roblox's Roblox Privacy and Cookie Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision engages the CCPA and CPRA, which define 'sharing' personal information for cross-context behavioral advertising as a regulated activity requiring opt-out rights; the California Privacy Protection Agency (CPPA) and California Attorney General enforce these requirements. GDPR Article 6 requires a lawful basis for this processing, and GDPR Article 7 requires freely given, specific, informed, and unambiguous consent for advertising-related processing in the EU; the ePrivacy Directive also applies to cookie and tracking technology use in the EU. (2) GOVERNANCE EXPOSURE: High. The use of third-party pixels, SDKs, and advertising networks on a platform with a substantial minor user population creates layered compliance exposure; the policy states behavioral advertising is restricted for users below applicable age thresholds, but the technical enforcement of this restriction would be subject to regulatory scrutiny. (3) JURISDICTION FLAGS: California residents have explicit opt-out rights. EU/EEA users require consent-based mechanisms under GDPR and ePrivacy. UK users require compliance with UK GDPR and the UK ICO's guidance on cookies and advertising. Age-gating for advertising purposes is subject to heightened scrutiny under COPPA for under-13 users and under the California Age-Appropriate Design Code for users under 18. (4) CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with advertising and analytics partners must address restrictions on processing minor user data, data retention limits, and cross-context sharing obligations; procurement teams should verify that partner agreements include appropriate CCPA business purpose limitations and GDPR Article 28 data processing addenda. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review the consent management platform (CMP) used for EU/UK users to confirm it meets the IAB TCF or equivalent standard; audit the list of third-party advertising and analytics partners receiving data; verify that the 'Do Not Sell or Share' opt-out mechanism functions correctly and applies to all relevant data flows; and assess whether SDKs embedded in the Roblox app are covered by the policy disclosures.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC has jurisdiction over unfair or deceptive data practices under Section 5 of the FTC Act, including the use of tracking technologies and behavioral advertising disclosures
    File a complaint →
  • State AG
    California's Attorney General and the California Privacy Protection Agency enforce CCPA/CPRA opt-out rights for behavioral advertising data sharing
    File a complaint →

Applicable regulations

BIPA
Illinois, USA
CCPA/CPRA
California, USA
COPPA
United States Federal
Connecticut Data Privacy Act Amendments
US-CT
CAN-SPAM
United States Federal
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
UK GDPR
United Kingdom
Universal Opt-Out Mechanism Expansion 2026
US
VPPA
United States Federal

Provision details

Document information
Document
Roblox Privacy and Cookie Policy
Entity
Roblox
Document last updated
May 5, 2026
Tracking information
First tracked
May 12, 2026
Last verified
May 12, 2026
Record ID
CA-P-011400
Document ID
CA-D-00073
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
65526103181ac7fe55d4543ce0b351c34dc032fe69a8add53e6f30543ae9d94a
Analysis generated
May 12, 2026 09:41 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Roblox
Document: Roblox Privacy and Cookie Policy
Record ID: CA-P-011400
Captured: 2026-05-12 09:41:40 UTC
SHA-256: 65526103181ac7fe…
URL: https://conductatlas.com/platform/roblox/roblox-privacy-and-cookie-policy/behavioral-advertising-and-cross-context-data-sharing/
Accessed: June 29, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Roblox's Behavioral Advertising and Cross-Context Data Sharing clause do?

This provision authorizes third-party advertising partners to collect your behavioral and activity data across platforms using tracking technologies, which under California law constitutes 'sharing' personal information and triggers opt-out rights.

How does this clause affect you?

Adult and teen users on Roblox may have their in-platform behavioral data and identifiers shared with advertising and analytics partners for targeted advertising; California residents have the right to opt out of this sharing under CCPA/CPRA.

Is ConductAtlas affiliated with Roblox?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Roblox.